1

Task Order 3003 – General Technical and Programmatic Support for Regulatory 

Development

Technical Directive Number 17, Task 2, Subtask e – Internal Lining Failures

Summary of Internal Lining Failure Analysis

July 29, 2009

1.0 Background

This summary document reports the methodologies and findings of an information review related 

to the internal linings of underground storage tanks (USTs). One appendix is also included

(Appendix A: Lining Inspection Company Contact List).

2.0 Internal Lining Failure Summary

Methodology

By contacting not more than nine lining inspection companies1, E2 Inc. determined:

 The total number of lining inspections conducted by the companies over the past ten 

years (1999-2009).

 The number of the companies’ lining inspections that did not pass inspection.

 The number of the lining inspection failures identified that could be repaired in 

accordance with a code of practice.

 The number of the lining inspection failures identified that could not be repaired in 

accordance with a code of practice.

The contractor used the PEI Web site (www.pei.org) and general Internet searches to develop a 

list of potential lining inspection companies. E2 Inc. reviewed the list with the EPA subject 

matter expert before finalizing the list of nine companies. 

Results

Eight of the nine lining inspection companies contacted provided information estimates. The 

other company (Tank Liners) no longer provides lining inspections and was not able to provide 

any data. Five companies estimated the total number of lining inspections that they have 

conducted over the past ten years. The other three companies were able to provide an estimate 

for the past year. These companies indicated that annualizing that number over the past decade 

would be the best way to estimate the total number of lining inspections that they had conducted.

For these companies, the contractor multiplied their annual estimates by ten. 

Four of the companies conduct fewer than 100 lining inspections annually. One company (Tank 

Tech) is a high-volume inspector, conducting approximately 1,000 lining inspections annually

(Table 1). The four companies that conduct at least 100 inspections annually estimated the 

percentage of lining inspection failures at between five percent and 16 percent. The four

companies that conduct fewer than 100 inspections annually had a wider estimate range for the 

number of lining inspection failures: between seven percent and 57 percent (Table 1).

 

1

In order to comply with the Paperwork Reduction Act, no more than nine contractors were contacted.
2

Of the six companies that provided estimates regarding the number of lining inspection failures 

that could be repaired in accordance with a code of practice, 50 percent was the lowest estimate 

provided for the percentage of these linings that were repairable. Four companies indicated that 

at least 75 percent of the linings were repairable, with one of these companies stating that 

virtually all linings (99 percent) were repairable (Table 1). Multiple companies stated that most 

tanks can be repaired, but that many repairs are cost-prohibitive, with replacement recommended 

as the alternative approach.

Taken together, the companies contacted estimated that they have conducted a total of 15,590 

lining inspections over the past ten years, or 1,559 annually (Table 1). In total, the companies 

estimated that 12 percent (1,800 – 1,850) of these USTs did not pass lining inspections (Table 1). 

Of these USTs, the companies estimated that 77 percent (1,307 – 1,352) could be repaired in 

accordance with a code of practice (Table 1). The companies estimated that twenty-three percent 

(384 – 389) of these USTs could not be repaired in accordance with a code of practice (Table 1). 

These company estimates were then extrapolated to the total number of USTs in the United 

States (Table 1). Based on UST data from TO 3003, TDD #5, it is estimated that five percent 

(30,831) of the 616,613 USTs in the United States are lined USTs that could have had lining 

inspections conducted over the past ten years (Table 1). Twelve percent (3,700) of these USTs 

may not have passed lining inspections (Table 1). Of these USTs, 77 percent (2,849) could have 

been repaired in accordance with a code of practice (Table 1). Twenty-three percent (851) of 

these USTs would not have been repairable in accordance with a code of practice (Table 1).

Annualized, lining inspections could have been conducted for a total of 3,083 USTs each year 

(Table 2). There could have been 370 USTs each year that may not have passed the lining 

inspections (Table 2). Of these USTs, there could have been 285 that could have been repaired 

in accordance with a code of practice and 85 that could not have been repaired in accordance 

with a code of practice (Table 2). 

The interviews also provided some additional information that may be of interest to OUST: 

 According to several companies, new regulations and state laws are the primary driver of 

the lining inspection process, leading to updated codes of practice.

 The repairability of tank linings varies from state to state (i.e., lining regulations in one 

state may mandate the replacement of a tank, whereas that lining would be repairable in a 

neighboring state). Pennsylvania, for example, does not permit the repair of UST linings.

 Several companies anticipate that the failure rate of tank linings will drop over time, 

because the quality of tank linings and lining repairs has improved significantly over 

time. One exception, according to one company: the increased storage of ethanol in 

USTs has led to an increase in tank lining failures.
3

Table 1. Lining Inspection Failure and Repair Findings

Lining Inspection 

Company

Total Number 

of Lining 

Inspections 

Conducted 

Over Past 10 

Years

Number / %

of Lining 

Inspections 

That Did Not 

Pass 

Inspection

Number / % of 

These Lining 

Inspections That 

Could Be Repaired 

in Accordance with 

a Code of Practice

Number / % of These 

Lining Inspections 

That Could Not Be 

Repaired in 

Accordance with a 

Code of Practice

Advanced Fuel Systems 140 80 / 57% 40 / 50% 40 / 50%

AmTech Tank Lining & 

Tank Repair

1,000 50 – 100 / 

5% - 10%

45 – 90 / 

90%

5 – 10 / 

10%

Center Point Tank Services 100 10 / 10% data not available* data not available*

Fuel Tank Maintenance 450 250 / 56% 125 / 50% 125 / 50%

Northwest Tank Inspections 900 60 / 7% 59 / 99% 1 / 1%

Tank Liners company no longer conducts inspections and did not provide data

Tank Tech 10,000 1,000 / 10% 850 / 85% 150 / 15%

Tanknology 1,400 100 / 7% data not available* data not available*

WCC Tank Technology 1,600 250 / 16% 188 / 75% 63 / 25%

Totals: 15,590 1,800 – 1,850 

/ 12%

1,307 – 1,352 / 

77%

384 – 389 / 

23%

Extrapolated Findings

% of Lined 

Tanks in 

United States

(Estimate 

from TO 

3003, TDD 

#5)

Total 

Number 

of USTs 

in United 

States

Extrapolated

Number of 

Tanks That 

Could Have 

Had Lining 

Inspections 

Conducted 

Over Past 10 

Years

Extrapolated 

Number / %

of These 

Lining 

Inspections 

That Did Not 

Pass 

Inspection

Extrapolated 

Number / % of 

These Lining 

Inspections That 

Could Be Repaired 

in Accordance with 

a Code of Practice

Extrapolated

Number / % of These 

Lining Inspections 

That Could Not Be 

Repaired in 

Accordance with a 

Code of Practice

5% 616,613 30,831 3,700 / 12% 2,849 / 77% 851 / 23%

Note: data provided by all companies contacted are estimates. Due to rounding, 

some numbers will not total as expected.

* company does not repair linings.

 Lining inspections conducted by Center Point Tank Services and Tanknology 

not included in estimate, due to lack of data availability.

 Estimate from TO 3003, TDD #5. Estimate from review of UST equipment 

currently in use for federally regulated USTs in 23 states. 

 UST Corrective Action Measures Report for Mid-Year FY 2009.
4

Table 2. Annualized Data Totals from Lining Inspection Company Interviews and Data 

Extrapolation

Annualized 

Number of 

Lining 

Inspections 

Conducted 

Over Past 10 

Years

Annualized

Number / %

of Lining 

Inspections 

That Did Not 

Pass 

Inspection

Annualized 

Number / % of 

These Lining 

Inspections 

That Could Be 

Repaired in 

Accordance 

with a Code of 

Practice

Annualized 

Number / % of 

These Lining 

Inspections 

That Could Not 

Be Repaired in 

Accordance 

with a Code of 

Practice

Annualized Lining Inspection 

Company Interview Data

1,559 180 – 185 / 

12%

131 – 135 / 

77%

38 – 39 / 

23%

Annualized Extrapolated Lining 

Inspection Data

3,083 370 / 12% 285 / 77% 85 / 23%
5

Appendix A. Lining Inspection Company Contact List

Lining Inspection Company Dates of 

Contact Contact Method and Information

Advanced Fuel Systems

Columbus, OH

www.advfuel.com

06/29/09

07/07/09

Steve Thickstun

e-mail: steve@advfuel.com

AmTech Tank Lining & Tank Repair

Plymouth, NH

www.armorshielding.com

06/25/09

07/02/09

Dennis Paquet

telephone: (888) 839-0373

Center Point Tank Services

Douglasville, PA

www.cptank.com

06/29/09

06/30/09

07/02/09

Roger Tartaglia

telephone: (610) 385-4977

Fuel Tank Maintenance

Cookeville, TN

www.fueltankmaintenance.com

06/29/09

07/06/09

07/11/09

07/15/09

Brandon Mack

telephone: (931) 528-1137

Northwest Tank Inspections

Vancouver, WA

07/09/09 Scott Borders

telephone: (360) 253-3619

Tank Liners

Beaverton, OR

www.tankliners.com

06/25/09

07/02/09

07/07/09

07/15/09 

07/21/09

e- mail: albert@tankliners.com 

telephone: (503) 965-4678

Tank Tech

Blodgett, MO (headquarters)

www.tanktech.com

06/25/09

07/02/09

07/05/09

Rob Russell

telephone: (573) 471-1932

Tanknology

Austin, TX (headquarters)

www.tanknology.com

06/25/09

06/30/09

07/02/09

Bert Schutza

e-mail: bschutza@tanknology.com

WCC Tank Technology

Newburgh, NY

06/25/09

07/02/09

07/15/09 

07/17/09 

07/20/09

Bob Deitz

telephone: (845) 564-9555

e-mail: wcctank@yahoo.com